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Maritime Compliance Report

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As we wait for the results of the investigation into the BP/ Deepwater Horizon oil spill in the Gulf of Mexico, one thing appears fairly certain based upon currently published information, and that is that corners may have been cut and unnecessary risks may have been taken. This is not really surprising. We cut corners and take calculated risks every day, often with no negative consequences. Who has never exceeded the speed limit while driving? The natural reaction of politicians and bureaucrats is to make more laws and regulations to fix the problems before we know for sure what the problems are. We may find that the problem wasn’t a lack of adequate laws and regulations, but perhaps it was the lack of enforcement, oversight and compliance with the existing laws and regulations. If so, why would the level of enforcement, oversight and compliance drop to a level where an accident like this might occur? Perhaps because they had not had a major accident with similar operations in the recent past to remind them of the threat. BP was reportedly celebrating a safety milestone at the time of the disastrous blowout. If people have not experienced a major accident in quite some time, their minds allow them to believe the threat has become diminished. In actuality the threat has not diminished with the passage of time, but still corners are cut and unnecessary risks are taken, because the precautions that once seemed necessary may now seem like overkill.
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The U.S. Environmental Protection Agency (EPA) issued a Vessel General Permit (VGP) which went into effect in the U.S. in February of 2009. The purpose of the VGP is to regulate discharges into the water which are incidental to normal operations. In general, the VGP applies to all commercial vessels which are greater than 79 feet, U.S. or foreign flag, operating in U.S. waters. This includes otherwise unregulated deck and hopper barges as well. There hasn’t been much enforcement of the EPA VGP to date, but, according to the EPA, they are developing a Memorandum of Agreement with the U.S. Coast Guard (USCG) regarding how the USCG will enforce this on behalf of the EPA. So, you may not see any enforcement for quite a while, but when they show up they will want to see documentation going back as far as February 2009 as evidence that the VGP has been followed.
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The VGP identifies 28 types of incidental discharges which may occur from vessels, including: sacrificial anodes, gray water, elevator pit effluent, controllable pitch propellers hydraulic fluid, deck run-off, etc. Recognizing that totally eliminating discharges may be an unachievable goal, the EPA requires vessels to establish and follow best management practices (BMP) to minimize these discharges, such as wiping galley dishes free of oil and grease prior to placing them in the sink. The EPA has indicated during conversations that this kind of BMP may be verified by USCG or EPA inspectors who may ask an unsuspecting crewmember, “What do you do with that plate after you’re done eating?” The VGP is another form of performance-based regulation such as ISM and ISPS. The same pitfalls are associated with this VGP as are found with other performance-based programs. The key to compliance with performance-based programs is in the implementation and training. Unfortunately, implementation and training levels are usually commensurate with the level of enforcement, which can be inconsistent. Since we do not yet know how the VGP will be enforced, the VGP best management practices may run the risk of becoming another “book on the shelf.” Of course, there are requirements for record keeping and inspections which must be provided to enforcement personnel upon request in order to verify compliance.   In order to avoid that situation and the costly penalties associated with it, vessel operators should consider the following: Draft best management practices in accordance with the VGP which cover all applicable discharges. The best management practices should meet the requirements of the VGP, but be realistic and able to be implemented. Go through the VGP and produce a comprehensive system of logs and records which will cover every aspect of the VGP, including the corrective action. Don’t wait until you have something to correct to look at the requirements. Train all vessel personnel on the requirements of the VGP on a regular basis. Finally, always keep in mind the intent of the regulation, because that is how the enforcement person will approach it. For example: If your vessel discharges gray water over the side, and an inspector asks a crewmember what he does with the dishes prior to putting them in the sink; if the crewmember starts explaining about separating garbage, but fails to mention that he wipes each plate free of oil and grease, you could be subject to a violation.
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The latest trend in regulatory schemes is performance based regulations. This type of regulation usually requires the regulated entity to come up with a plan or system which will meet the performance based criteria in the regulations, such as International Safety Management (ISM) and the impending towing vessel inspection regulations. Some organizations also require member companies to implement a Safety Management System (SMS), such as the American Waterways Operators (AWO) Responsible Carrier Program (RCP). Regardless of the source, not fully implementing and complying with these plans can have serious consequences in the event of an accident.
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